Effective date: May 10, 2018
OfferDaddy.com offers walls (both web and SDK for mobile apps) ("us", "we", or "our") operates the https://www.offerdaddy.com offers walls and the OfferDaddy Android and iOS SDK for mobile application (the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on a User’s device.
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject is any living individual who is the subject of Personal Data.
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
We collect several different types of information for various purposes to provide and improve our Service to you.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").
This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Session Cookies. We use Session Cookies to operate our Service.
We uses the collected data for various purposes:
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Uruguay and choose to provide information to us, please note that we transfer the data, including Personal Data, to Uruguay and process it there. As well, we store and process data at other locations such as United States and to offer a better and faster Service we may also store and process data at other locations around the world (replicated data).
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We may disclose your Personal Data in the good faith belief that such action is necessary to:
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at firstname.lastname@example.org
In certain circumstances, you have the right:
You have the right to data portability for the information you provide to us. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
Please note that we may ask you to verify your identity before responding to such requests.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
The aim of this top-level Policy is to define the purpose, direction, principles and basic rules for information security management.
This Policy is applied to the entire Information Security Management System (ISMS), as defined in the ISMS Scope Document.
Users of this document are all employees of OfferDaddy.com, as well as relevant external parties.
Confidentiality – characteristic of the information by which it is available only to authorized persons or systems.
Integrity – characteristic of the information by which it is changed only by authorized persons or systems in an allowed way.
Availability – characteristic of the information by which it can be accessed by authorized persons when it is needed.
Information security – preservation of confidentiality, integrity and availability of information.
Information Security Management System – part of overall management processes that takes care of planning, implementing, maintaining, reviewing, and improving the information security.
General objectives for the information security management system are the following: creating a better market image, reducing the damage caused by potential incidents, user satisfaction and proper serving of users of our platform(s); goals are in line with the organization's business objectives, strategy and business plans. OfferDaddy.com’s Director is responsible for reviewing these general ISMS objectives and setting new ones.
Objectives for individual security controls or groups of controls are proposed by the Director of OfferDaddy.com and his Assistants, support employees, development team in rare occassions, business development staff and account managers, and approved by OfferDaddy.com’s Director in the Statement of Applicability.
All the objectives must be reviewed at least once a year.
OfferDaddy.com will measure the fulfillment of all the objectives.
OfferDaddy.com’s Director is responsible for setting the method for measuring the achievement of the objectives – the measurement will be performed at least once a year and OfferDaddy.com’s assistants will analyze and evaluate the measurement results and report them to OfferDaddy.com’s Director as input materials for the Management review.
This Policy and the entire ISMS must be compliant with legal and regulatory requirements relevant to the organization in the field of information security, as well as with contractual obligations, data secrecy, personal data protection of OfferDaddy.com's publishers and their users.
The process of selecting the controls (safeguards) is defined in the Risk Assessment and Risk Treatment Methodology.
Responsibilities for the ISMS are the following:
The Director has to ensure that all employees of OfferDaddy.com, as well as appropriate external parties are familiar with this Policy.
Hereby the OfferDaddy.com’s Director declares that ISMS implementation and continual improvement will be supported with adequate resources in order to achieve all objectives set in this Policy, as well as satisfy all identified requirements.
This document is valid as of May 10, 2018.
The owner of this document is OfferDaddy.com’s Director, who must check and, if necessary, update the document at least once a year.
When evaluating the effectiveness and adequacy of this document, the following criteria need to be considered: